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 TTB Notice No. 41 CommentsFORM LETTER 15 Chief, Regulations & Procedures Division Dear Chief:
Current federal alcohol beverage label regulations do not allow most beer, wine and distilled spirits companies to provide information about their products so that consumers can make informed choices about what to drink and how much to drink. TTB is to be commended for seeking public comment on this proposed change in regulations.
Food, soft drinks, over-the-counter drugs, and even dietary supplements provide consumers with basic consumer information on the label. Alcohol beverages (with some exceptions) are the only major class of consumable goods that do not provide this type of information on the label. TTB should allow labels voluntarily to list information such as serving size and servings per container, as well as alcohol, calories, fat, carbohydrates and protein per serving.
Of all this information, the amount of alcohol per serving would be highly beneficial for consumers to have.
The
The majority of American adults consume alcohol. Those who do so should drink alcoholic beverages in moderation. Moderation is defined as the consumption of up to one drink per day for women and up to two drinks per day for men. Twelve fluid ounces of regular beer, 5 fluid ounces of wine, or 1.5 fluid ounces of 80-proof distilled spirits count as one drink for purposes of explaining moderation. (p. 44)
Allowing, but not requiring, the placement of information on alcohol per serving and servings per container on beer, wine and distilled spirits labels will help consumers to better understand the government's advice. In fact, given the wide variety of formulations, container sizes and alcohol concentrations in today's products, and the regulatory disparities as to what information may be placed on beer, wine and distilled spirits labels, some consumers might welcome more information about how particular products relate to the Guidelines' advice.
Consumer Serving Facts will be more meaningful if TTB makes clear in this rulemaking what constitutes a "serving." This is the essential fact that will allow consumers to make more informed comparisons between products and better understand what is in a standard serving of any alcohol beverage.
The standard serving definition used in the Dietary Guidelines (12 ounces of regular beer, 5ounces of table wine and 1.5 ounces of 80 proof distilled spirits) is one widely used by
I urge TTB to act expeditiously to promulgate a regulation that permits meaningful consumer-oriented serving facts on beer, wine and spirits labels. Meanwhile, I urge TTB to allow manufacturer' to provide this kind of truthful, non-misleading information on labels while the rulemaking process proceeds.
Sincerely, [Brewery/Business/Association Name Here] |
